The NDT Section of a Ship Repair Yard's Quality Manual

The scope trap: W35 was rewritten around new construction

UR W35 Rev.1 clause 1.1(i) reads that firms providing Non-Destructive Testing and Advanced Non-Destructive Testing services on the new construction of ships and offshore structures subject to classification need to fulfil the requirements set out in the Unified Requirement. The 2019 original said something wider: services on ship and offshore structures and components subject to classification. The words new construction were added in Rev.1, which IACS societies implement uniformly from 1 January 2025.

Clause 1.1(ii) confirms the reach. The requirement applies to independent NDT companies and to internal departments of fabricators, naming shipyards and hull block or section fabricators performing NDT, and it lists the covered items as welding of components integrated into the structure, fabrication of independent fuel or cargo tanks, hull structure as defined in UR Z23, and rudders of welded construction. Clause 1.1(iii) removes W35 suppliers from the scope of Z17 and leaves the verification method to each society.

For a repair yard the practical effect is that no single unified requirement names it. That is not a licence. It means the yard's NDT obligations get assembled from the class society's own rules and the repair specification for the ship in dock, from NAVSEA's technical publication where the work is Navy work, and from Z17 where the scope crosses into thickness gauging. A quality manual built around one of the three fails an audit conducted under another.

What the quality manual has to contain for NDT

W35 clause 2.2 carries the most complete published list of what an NDT quality system covers, and it is the right skeleton for a repair yard whether or not the Unified Requirement names the yard. It runs through a code of conduct for the activity; maintenance and calibration of equipment; training programmes; maintenance of records for operators' and supervisors' training, qualification and certification; certification of operators including re-validation and recertification; a procedure for testing operators' visual acuity; and a procedure for the supervisor's authorisation of NDT operators.

The list continues into supervision and verification of operation to ensure compliance with the NDT procedures; recording and reporting of information, including retention time of records; periodic review of work process procedures; corrective and preventive action; feedback and continuous improvement; internal audits; and provision of accessibility to the required codes, standards and procedures to assist operators. Retention time is a field the yard fills in with a number, not one the requirement fills in on its behalf.

Clause 2.2 then names ISO/IEC 17020 and the inspection body types, and closes with a sentence that settles an organisational question most yards have already answered wrongly: in all cases, production staff shall not be allowed to inspect their own work in the case of a Type C inspection body. A yard whose NDT technicians report through the production manager who owns the schedule is carrying an impartiality finding that no procedure revision will close.

The written practice, and where class will and will not accept it

W35 clause 2.3 sets the hierarchy plainly. The NDT service supplier is responsible for the qualification and preferably third-party certification of its supervisors and operators to a recognised certification scheme based on ISO 9712. Employer-based qualification under SNT-TC-1A or ANSI/ASNT CP-189 is acceptable where the supplier's written practice is reviewed and found acceptable by the society, and that written practice has to comply as a minimum with the requirements of ISO 9712, excepting the impartiality requirements of a certification body.

The clause that catches a repair yard running a mobile workforce follows immediately. For operators holding certificates issued via an employer-based scheme, the employer's certification is deemed revoked when employment is terminated by either party. A technician who left last month took nothing portable with him. The yard hiring him either certifies him afresh under its own written practice, or documents its acceptance of prior certification under rules the written practice already contains and can show an auditor.

The current edition of SNT-TC-1A is 2024, with an addendum in effect from May 2025, and it added the ASNT 9712 programme to the routes it recognises alongside clarified definitions and tighter rules on vision testing. A written practice still citing a 2016 edition is a dated document in front of a surveyor who has read the current one. Written practice development is the workstream that closes the distance between an employer scheme that works internally and one a society accepts in writing.

Level 3: the position a yard cannot appoint its way out of

W35 clause 2.4 requires the supplier to employ, on a full-time basis, at least one supervisor independently certified to Level 3 in the methods concerned, and states directly that it is not permissible to appoint Level 3 personnel, who must be certified by an accredited certification body. Clause 2.3 closes the same door from the employer-scheme side: it is not permissible to directly appoint a Level 3 without examination where the intended route is an employer-based scheme.

The clause then makes room for how yards actually staff. Where the supplier does not hold a Level 3 in every method practised, it is permissible to employ an external, independently certified Level 3 in the methods the full-time Level 3 does not hold. By agreement with the society, the supplier may instead appoint an internal full-time supervisor certified to a minimum of Level 2, provided it engages external Level 3 services on a part-time or contract basis for procedure development, procedure approval, consultancy and review.

Whichever route the yard takes, the duties attached to the role are enumerated and dated. Validate NDT instructions and procedures established and reviewed by Level 3 personnel. Review NDT reporting. Supervise all tasks and operations at all levels. Inspect NDT equipment, tools and calibration. And re-evaluate the qualification of the operators annually on behalf of the supplier. That annual re-evaluation is the item that lapses first, because it is a documented act with a date rather than a standing assumption, and ASNT Level III consulting services exist to carry exactly this list.

Navy work runs on a different book, and it is stricter

NAVSEA T9074-AS-GIB-010/271 Revision 1 covers radiographic, magnetic particle, liquid penetrant, ultrasonic, eddy current and visual testing, and it states its own limits plainly. It contains no acceptance criteria, which sit in the applicable fabrication document, and it does not cover NDT performed underwater, which goes to NAVSEA S0600-AA-PRO-070. Clause 1.6 then does the thing that separates Navy work from commercial work: SNT-TC-1A, as modified, is invoked as mandatory minimum requirements and is not to be considered as recommendations or guidelines.

The clocks are fixed and short. Clause 1.6.4 recertifies NDT personnel at intervals not greater than three years and Examiners at not greater than five, and expressly refuses recertification by evidence of continuing satisfactory technical performance or on the basis of ASNT certifications granted without examination. Clause 1.6.10.1 requires at least one documented evaluation every twelve months, chosen from a witnessed in-process inspection, a reinspection of previously inspected product, or a technical performance evaluation. Clause 1.6.10.2 requires a technical performance evaluation before the end of the second year of the cycle for anyone performing acceptance inspections.

Clause 1.7.2 sets a procedure bar above ordinary commercial practice. Each procedure has to have been qualified by proving that known discontinuities, natural or artificial, can be reliably detected and evaluated, with those discontinuities representative of typical expected flaw types and of a size near the threshold of acceptance and rejection. The data documenting that demonstration goes to the Government inspector on request. The wider picture, including the Examiner's own specific examination, sits on our page covering NAVSEA NDT requirements for shipyard work.

What the yard self-performs, and what it has to buy

Employer certification carries a great deal of the yard's work. A repair yard with an accepted written practice, a qualified Level 3 or Examiner, approved procedures and a functioning records system self-performs weld NDT on its own repair welds. That is the bulk of the volume in any dock period: magnetic particle and penetrant on gouged-out and rewelded seams, ultrasonic on insert plates and doublers, visual throughout, and radiography where the specification calls for it.

Two scopes do not travel that route at all. Hull thickness gauging whose readings feed a class survey requires a firm holding a Certificate of Approval under UR Z17, renewed at intervals not exceeding three years, with the attending surveyor verifying each separate job by signature. In-water survey by diver or remotely operated vehicle is a separate Z17 category carrying its own approval. A yard that gauges a hull for a survey on the strength of its own written practice has performed unapproved work on a statutory survey.

The decision is therefore commercial before it is technical. A yard that wants the gauging scope in-house pursues firm-level approval and runs it as a standing capability, which is the ESP survey readiness route and the subject of our work on IACS service supplier approval. A yard that does not buys the scope from an approved firm and controls the purchase instead, and that is a different discipline with its own failure modes.

Subcontractor control when the NDT is bought in

Both class requirements say the same thing in nearly the same words. W35 clause 2.8 requires the supplier to give information of agreements and arrangements where any part of the services is subcontracted, including Level 3 services, to give emphasis to the subcontractor's quality management system in following up those subcontracts, and states that subcontractors meet the same requirements placed on NDT service suppliers for any NDT performed. Z17 clause 5.2.9 mirrors it for service suppliers generally.

NAVSEA draws the boundary harder than either. Clause 1.5.3 defines an activity as all sites of an organisation under the same quality assurance management and using the same quality assurance plan. A subcontractor is therefore a different activity: it holds its own written practice, its own Examiner and its own certification records. Clause 1.6.9 prohibits transfer of NDT certifications to other activities except as authorised by NAVSEA, so a certificate the subcontractor issued never becomes the prime yard's certificate.

What that means on the purchase order is concrete and short. Name the certification scheme and the level required of the report signatory. Name the procedure by number and revision, and require that a Level 3 certified in that method approved it. Name the acceptance criteria document. Require the calibration and verification record for the specific instrument used on your job. And retain the right to witness. Everything the yard cannot evidence at audit is something the purchase order failed to demand in the first place.

Records: what to keep, who signs, and for how long

NAVSEA clause 1.6.8 is the most specific published list of NDT personnel records anywhere in the marine sector. Records of qualification training and experience obtained prior to initial certification, maintained as long as the person is certified. Results of all current examinations that can be correlated to the examination administered, plus a master copy of each examination. Records of vision tests noting corrective aids, maintained for the current and preceding certification period. And a certification statement signed by the activity's Examiner for operators and inspectors.

The vision requirement behind that record is clause 1.6.7.1: an annual test conducted by a qualified technician, requiring natural or corrected near acuity sufficient to read J1 letters on the Standard Jaeger chart at not less than twelve and no more than sixteen inches, met by one or both eyes, plus colour differentiation where the work requires it. Clause 1.6.7.2 requires the corrective aids used during the vision test to be used during the certification examination and all subsequent inspections and tests.

Retention beyond the personnel file is set by the customer rather than the yard. The ESP Code keeps the survey report file, thickness measurement reports included, on board for the lifetime of the ship. W35 clause 2.9 requires all NDT to be documented so the testing can be retraced or repeated at a later stage, referencing the applicable standard, procedure and acceptance criteria, and signed by personnel holding the appropriate certification level and the signatory status the quality system defines. Write a retention period into the manual that survives both.

The audit sequence, and the order that saves rework

Audits open in a predictable order and a yard should rehearse them in that order rather than in the order its manual is written. The quality manual and NDT procedures first, because a finding there invalidates everything downstream of it. Then the written practice, read against the certification scheme it claims to implement. Then a sample of personnel files, opened at the record fields the requirement names rather than at the certificates on top. Then equipment and calibration records, instrument by instrument. Then a live job.

NAVSEA Standard Item 009-04 sets the surrounding quality management expectation for Navy contract work: a quality manual and documented procedures meeting the ISO 9001 requirements it invokes, a test and inspection plan, records of tests and inspections accomplished, process control procedures submitted to the Supervisor a minimum of fourteen days before use, and corrective action responses carrying root cause analysis and objective quality evidence. Those fourteen days are a scheduling constraint on the production plan, not a formality.

Yards already carrying open findings are better served by an NDT programme audit and gap assessment run against the specific requirement the next audit will use than by a general rewrite of the manual. The output is a numbered finding list with an owner and a date against each line, produced the same way a surveyor would produce it. Atlantis is affordable, accessible and fully customisable, and we scope this against the yard's actual work mix, whether that is commercial class, Navy, or both. Start through contact.

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